RESPONSE
TO THE ROYAL SOCIETY REPORT ON
THE
HEALTH HAZARDS OF DEPLETED URANIUM (DU) MUNITIONS: Part 1.
1.. Disappointment.
1.. It is undeniable that this report has arisen from the repeated
concerns of Gulf War Veterans (GWVs) and the Balkan veterans but
immediately the investigation side-steps the issue of the GWVs
and moves
the agenda to a general consideration of the health hazards of
DU which
involves only calculations for increased risks of cancer.
2.. Other diseases are excluded because the ICRP model only considers
cancer. This is a serious omission since it is recognised that
ionising
radiation can cause a variety of other diseases affecting the
central
nervous system, cardiovascular system, immune, respiratory, digestive
and urinary tracts, skin and reproductive problems, Bertell 1999,
and
Hooper, 1999, 2000.
3.. The evidence that would question the validity of the modelling
will
emerge mainly from cancers that develop 10-30 years after the
initial
exposures- with the exception of leukaemia and Doug Rokke's e-mail
with
details of the cancer deaths among his colleagues involved in
DU
assessment.. This leaves the GWVs in limbo and provides yet a
further
pretext for inaction by the MOD.
4.. However it is imperative that the records of the GWVs are
carefully
scrutinised for leukaemia- deaths and living sick veterans, ie
mortality
and incidence. So far from 32 deaths, where the medical records
are
known to the NGV&FA, there have been 4 cases of leukaemia.
The present
number of deaths is 527. The figures given in the report, 0.25
deaths
per 10,000 per annum in the 20-29 age group, equate to 12.5 deaths
from
leukaemia over 10 years in the 50,000 cohort of GWVs.
5.. The report fails to address the primary issue that GWVs were
placed,
possibly deliberately, in an experimental situation that involved
the
use of DU munitions which were known, since at least 1974, to
be
associated with major health hazards. I supplied detailed information
to
the Working Group.
6.. It makes no comment on the fact that no advice was given,
no
monitoring took place and no surveillance has been provided in
the 10
years since the end of the 100 hours war in 1991.
7.. It makes no judgement on what is, at the very least, gross
negligence and at the worst culpable homicide. [In discussion
it became
clear that the Working Group could not understand why no
measurements/investigations had been carried out by the MOD and
regarded
it as, at least, some dereliction of duty.]
8.. There is no consideration given to the known facts of UK GWVs
with
illnesses that are consistent with exposure to ionising radiation-.
9.. There is no consideration of the biology of exposure to radiation.
[Appendix 2 does cover part of this issue and identifies the 'bystander'
effect but regards the evidence in need of strengthening- two
papers
have been missed.]
10.. The recommended further studies do not include the very obvious
need to obtain data from the GWVs and Balkan veterans that will
indicate
the extent and possible levels of exposure to DU. It does mention
the
desirability of autopsy studies and in vivo tests. The latter
need very
advanced technology that is not readily available.
11.. It is already known that members of staff in field hospitals
are
among those with prolonged contamination with DU. These do not
feature
in the higher risk groups proposed in the arbitrary division of
exposure
into three levels, L1, L2, and L3. This raises questions about
the
validity of such proposals. Indeed the different levels are predicated
on the estimated risks derived from the ICRP models used. It is
a
circular argument.
12.. The frequent reference to high levels of exposure continues
the
commitment to the high exposure- soluble-high excretion model
that
reflects MOD thinking. This is the exact opposite of the model
for
exposure to insoluble, inhaled DU dust ie. low exposure-insoluble-
immobilised-low excretion rates. The low dose-slow dose effect
first
identified in 1972 by Petkau found that a 26,000 fold reduction
in dose
effectively destroyed cell membranes over 700 minutes compared
to 135
minutes for the higher dose. The low dose-slow dose exposure fits
very
precisely the expected situation faced by GWVs, Busby, 1995, Bertell
1999 for summary.
13.. The ability for DU particles to move long distances and be
re-suspended by light breezes and vehicle and plane movements
makes the
situation almost totally unpredictable. Measurements on the Gulf
and
Balkan veterans will provide reliable data and circumvent many
of the
theoretical suggestions for further research.
14.. There is no reference to the civilians of Iraq or to the
distressing figures emerging for childhood cancers and leukaemias,
birth
defects and low birth weights, and high abortion rates. Recent
studies
have identified 20 anophthalmos cases (babies born without eyes)
out of
a birth cohort of 4000. The natural levels of occurrence of these
tragic
cases is 1 in 50 million. The rate is therefore some 250,000 times!
the
expected rate, De Sutter, 2001.
15.. The civilians in the Balkan States are similarly ignored.
16.. The consideration of Balkan troops is sketchy and provides
no
reliable information about the level and extent of illnesses that
can be
associated with ionising radiation. Just a bland statement that
the
leukaemia cases found were not excessive. No evidence is put forward
to
support this statement and an examination of data available suggests
that excess leukaemia cases were found. [It is essential that
we obtain
accurate data, numbers and time span for every country whose soldiers
have reported leukaemia cases. From the unconfirmed figures I
have
received, largely through the press there has been a significant
increase in leukaemia deaths. These may be less that the actual
incidence. Both figures are required.]
a.. Compromised.
The Chairman
commented in an interview with 'Today' programme, BBC Radio
4, January 9th 2001, that DU weapons are "here to stay because
they are
very successful". A further interview on Radio 5 Live included
the
statement that "the aim [of the Working Group] was to reassure
GWVs that
they are not at risk [from DU]". The report outcome appears
to have been
decided before the Working Group commenced its work. The report
confirms
this pre-determined stance.
b.. Contradictory
and Timid.
The report
recognises and recommends the need for much more extensive
studies and also the limitations of the ICRP models used to reach
its
conclusions, particularly in regard to shrapnel fragments. However,
this
does not prevent firm conclusions being reached about the very
tiny
risks derived by these admittedly insecure calculations. The obvious
conclusion is that there should be, at the very least, a complete
moratorium on these weapons until much more information has been
obtained.
c.. Partial
and Biased.
1.. Key Witnesses are absent-
1.. (Major) Doug Rokke who has played a major part in the both
the
preparations for the Gulf War and its execution and follow-up.
He is
responsible for the evaluation of and training manuals for many
aspects
of DU munitions. [In discussion it was made clear that despite
requests
for information Dr Rokke had not supplied any information. This
is not
the case. In a number of e-mails Dr Rokke gave references to key
material that he stated was in the hands of the MOD. It became
clear
that the MOD had not supplied any documents to the Working Group.
What
was not clear was whether the specific documents mentioned were
ever
requested. The only document reported in the discussion was that
associated with Paul Musgrove- the MOD were unable to find this
document
despite searching for it.]
2.. Dr Asaf Durakoviae has carried out investigations into DU
contamination of UK veterans and those from other countries, including
Iraq, and Iraqi civilians. He is the only person to have done
such work.
He is listed among those submitting a written response to the
Working
Group but nowhere is there any reference to his published work
in this
field. [In discussion it emerged that Dr Durakoviae had offered
to
supply documents but only when they had been peer-reviewed and
published. In view of the Working Groups concerns about peer review
this
is a reasonable and wise decision.]
3.. Dr Pat Horan collaborated with Dr Durakoviae and developed
the
protocols for testing urine samples in which levels of DU were
accurately and unequivocally determined.
4.. Dr Rosalie Bertell who has worked in this field for many years
and
specialises in aspects of epidemiology and biological tests- none
of
these are referred to nor was she asked for evidence.
5.. Dr Hari Sharma who did much of the early work on measuring
DU in
urine samples and did the first risk calculations - giving very
different estimates from those in the report. These ranged from
1,500 to
10,500 extra cancers among the UK cohort of 53,000.
6.. Dan Fahey who authored a major report that brought together
information from military manuals that addressed the use of DU
munitions
in the field - this is not referenced in the report but supplies
important commentary/correction of the official army reports quoted.
7.. Nothing is said about the leaked AEA Technology report that
forecast
500,000 extra cancers over 10 years among the people of Iraq following
the release of 50 tons of DU aerosolised dust.
8.. GWVs were promised by the Chairman that they would be invited
to
give evidence to the Working Group. This did not happen. The GWVs
are
angry and disappointed and see this as a betrayal.
a.. The Literature
Referenced is Partial and Incomplete.
1.. Much is made of the of the Rand Report (Harley), OSAGWI reports,
and
the Institute of Medicine Report (Fulco) and the work of McDiarmid,
various industrial studies and the ICRP papers and models. All
these are
reports from within the establishment. Bernard Rostker, the Head
of the
Pentagon Investigation Unit into Gulf War Syndrome/Illness, was
formerly
at the Rand Corporation and commissioned the Rand reports. Harley,
by
her own admission, never read any of the primary documents concerning
DU
in the Gulf War.
2.. None of these reports, including the IOM report, give any
consideration to the effects of low level radiation.
3.. No reference is given for important papers that show the
well-founded and growing importance of low level radiation, the
deceit
and dishonesty in the nuclear industry and its compromised data
bases,
Busby, Martell, Bertell, Alvarez, the proposed changes in existing
data
base derived from the Hiroshima studies, Gofman, the possible
massive
underestimates of key values used in some of the calculations,
and the
significance of studies with small numbers of alpha particles.
One paper
from 1997 by Lehnert, and papers from Little, 2000, and Azzam,
1998, are
indexed in Appendix 2 but not referred to in the main report.
a.. Key Literature
Addressed Briefly or Not at All.
1.. Martell-"Secrecy, budgetary control, and the inherent
conflict of
interest...have compromised the objective assessment of the most
serious
aspects of radiation-induced cancer and other radiation health
problems." letter from Edward Martell to Hazell O'Leary,
US Secretary
Department of Energy, 9th Feb, 1994.
The control
of information and research programmes by these means has
woven a tissue of deception and misinformation around all things
pertaining to nuclear issues.
This letter
is extensively referenced and addresses issues raised in the
present report such as the effects of smoking on lung cancers
in uranium
miners.
It provides
references to cardiovascular disease and bone-seeking
nuclides (uranium is bone-seeking).
It emphasises
the importance of 'hot spots' over against whole body and
whole organ calculated exposures- something not considered in
the main
report.
b.. Gofman in his magnum opus raises the issues of maintaining
accurate
data bases that remain devoid of bias and the importance of the
effects
of low level radiation. His findings refute "claims by parts
of the
radiation community that very low doses or dose rates may be safe."
In a cri de
coeur he writes in 1979, "There is no way I can justify my
failure to help sound an alarm over these activities many years
sooner
than I did. I feel that at least several hundred scientists trained
in
biomedical aspects of atomic energy -myself included- are candidates
for
Nuremburg-type trials for crimes against humanity for our gross
negligence and irresponsibility. [But] now we know the hazards
of
low-level radiation, the crime is not experimentation, but murder."
This
is a fearful comment on the experiment in the Gulf War of the
use of DU
munitions, for the first time, with troops given no advice, protection,
or subsequent monitoring or surveillance.
c.. Busby has shown how misinformation and a refusal to consider
the
experimental evidence has led to led to estimates from official
models
being several hundred times too high.
ICRP risk factors
predicted there would be 1.1 extra cancers over 100
years among the 2.9 million people of Wales as a result of nuclear
fall-out. The number actually found after 10 years was 493. This
represents an error to date of 450 times the predicted value [4500
if
continued over 100 years] - see Wings of Death, 1995.
In a written
submission to the Working Group, Busby 2001, has also
described the inaccuracy of the linear extrapolations used at
low dose
for risk calculations that defies actual experimental observation.
The
cumulative radiological doses from oxide particles of uranium-238
are
also given in this submission. These vastly exceed the dose limit
set
for civilians and workers in the industry but there is no consideration
of this information in the report. This presentation is alluded
to but
not referenced whilst other presentations from the industry are
both
referred to and referenced.
d.. Kohnlein
in a paper posted on the web draws attention to work
published in 1992 and 1994 that includes experimental verification
that
the Relative Biological Effectiveness, RBE, of 20, used in most
calculations as a weighting factor for alpha particles, can be
very much
higher. In Chinese hamster ovary cells the weighting factor is
as high
as 6000 (Nagasawa and Little, 1992). There is no evidence that
this
figure has been taken onto account in any of the calculations
of risk
that have been presented. He calls for confirmatory studies and
the
absolute necessity for this large difference to be part of the
"design
and interpretation of epidemiological studies". This has
not been
considered in the modelling or the report.
Papers by Kadim
and co-workers include one on "alpha-particle-induced
chromosomal instability in human bone marrow cells" (Kadim
et al 1994).
The clinical histories of some GWVs include osteoporosis. If evidence
had been taken from the GWVs the importance of this paper would
have
been clear.
e.. Hei and colleagues described in 1997 and 1999 "The mutagenic
effects
of a single and exact number of alpha particles" in animal
and mammalian
cells. They showed that a single alpha particle can cause a mutation.
Although the Working Group was made aware of these papers they
have been
given no consideration and are not included in the references.
f.. Iyer and Lehnert described the bystander effect that multiples
the
effect of radiation, in non-irradiated cells, by 30-fold. This
is yet
another multiplier that requires inclusion in any risk assessment
of
alpha radiation. It is given only passing reference and not included
in
the references of the main report although there are 3 references
in
Appendix 2. These authors also provide a convincing scheme for
radiation-induced damage involving free radical mechanisms. This
provides sound grounds for synergistic interactions with other
toxins
used in the Gulf War and also good reasons for novel treatment
regimens
to counteract such processes. It is consistent with premature
aging
experienced by some GWVs.
g.. Vickers provided comprehensive schemes for the transmission
of the
effects of ionising radiation by biological mechanisms in 1993.
h.. Durakoviae and co-workers, Horan, Dietz, Sharma have studied
UK GWVs
and found that even 8 years after the Gulf War some of the sick
GWVs are
excreting DU in their urine. This indicates prolonged internal
contamination with very significant cumulative doses of alpha
particle
radiation almost certainly involving 'hot spots' in the lungs,
lymphatic
nodes and bone. None of this work is referred to or referenced.
i.. Bertell has described a useful blood test that might identify
significant damage from DU. This test provides a useful biological
test
that could be coupled with the clinical chemistry of DU detection
and
measurement. This information was provided but not used.
j.. Gong and colleagues have recently described a transferrin
receptor
assay test that is claimed to provide a biological marker of life-long
radiological exposure. Such a novel claim requires urgent study
but is
not mentioned in the report. The reference was provided.
k.. Versik-Peuchert has investigated one GWV and found unusual
chromosome breakage patterns which support exposure to ionising
radiation. This is another important biological mechanism that
offers
complementary biological data to go with any evidence of DU exposure.
Again information was provided but was not considered or referenced.
l.. Alvarez responded to an editorial in the British Medical Journal
by
Melissa McDiarmid which claimed that "Fifty years of occupational
exposure provides little evidence of cancer". This is the
view that
emerges from the Royal Society report in which McDiarmid is frequently
quoted with approval.
Alvarez-Director
Nuclear Policy Studies- draws attention to a major
report prepared at the request of the President of the USA. This
report,
July 1999, includes studies from major USA locations, Oak Ridge
Y-12
Weapons Plant, K-25 Gaseous Diffusion Plant, Tennessee, Fernald
Uranium
Processing Plant, Linde Air Products Co., NY, and Mallinkrodt
Chemical
Works, Missouri. Some of these are included in the final appendix
of the
report.
"The study
.. found elevated death rates for brain cancer, several
lymphopoetic (immune system) cancers, as well as cancer of the
prostate,
kidney, and pancreas. Excess death from breast cancer among women
was
found. ...excess lung cancer was their main finding. (Oakridge).
"Stomach
cancer.among salaried workers (261% higher)..statistically
significant increased death risks .for all cancers (21% higher)..lung
cancer (26% higher).evidence of a radiation-dose relationship
for both
non-malignant respiratory disease and lung cancer. (Fernald)
"Cancers
of the respiratory system, bone cancer, mental disorders and
all respiratory disease including pneumonia. .... increased risk
of
dying from cancer and chronic nephritis. The latter up by 600%
..when
deaths from the last decade of follow-up was observed. (Tenessee).
"Increased
risk of dying from all causes (18% higher), laryngeal cancer
(447% higher), all circulatory diseases (18% higher), arteriosclerotic
heart disease (19% higher), all respiratory diseases (52% higher)
pneumonia (217% higher) between 1943 - 9. (Linde).
"Increased
death rate from all cancers(10% higher). Respiratory
diseases, chronic nephritis/kidney disease (218% higher)..lymphatic
cancers were significantly higher..significant increased risks
.for
cancers of oesophagus (40% higher), rectum (45% higher), pancreas
(31%
higher), larynx (36% higher), kidney (34% higher), ..multiple
myeloma/bone marrow (33% higher). (Mallinkrodt).
This review
led "the Department of Energy to officially concede that
....nuclear workers were placed at risk of increased death and
disease."
m.. Weinberg et al. very recently reported in the Proceedings
of the
Royal Society that the children of liquidators, born after acute
and
chronic exposures to radioactive materials released after the
Chernobyl
accident showed a sevenfold increase in the number of new chromosomal
bands. "These results indicate that low doses of radiation
can induce
multiple changes in the human germline."
n.. McDiarmid reported the presence of DU in sperm as well as
neurocogniticve deficits and cardiovascular problems in the small
cohort
of GWVs with embedded DU fragments but this is not brought out
in the
Report or considered.
o.. De Sutter reported huge increases in anophthalmos in a birth
cohort
of 4000- see 1n above.
p.. El-Bayoumi summarises several key papers presented at 'Depleted
Uranium Symposium, Baghdad, 1998. Several authors describe large
increases in cancers amongst civilians and Iraqi veterans, low
birth
weights, and large increases in stillbirths and abortions. All
these
happened after the Gulf War. [It was suggested during discussion
on the
report that these could have arisen from the extensive use of
chemical
weapons in the Iran-Iraq war. From the time frame of the reports
this is
not possible.]
1.. Peer Review.
Comments in
the review, p17, exclude consideration of data from the low
level radiation group on grounds that it lacks rigorous peer review.
However, the Report makes much use of information that has not
been
rigorously peer reviewed- army reports, presentations to the Working
Group, the Harley report, the IOM report, monographs, etc. Indeed
the
Report under consideration has not been subject to peer review.
Peer review
is important but not the only criterion for good science and
has, in some instances, been known to hinder it.
b.. Further studies are imperative but not, primarily, the ones
proposed
in the report.
1.. An immediate, extensive and independent study should be made
of all
GWVs and Balkans veterans, or failing that very large numbers
which
satisfy statistical criteria, by urinanalysis for prolonged
contamination with DU.
2.. There should be similar studies on the civilian populations
of
exposed to DU in the Iraq, the Balkans, and round DU processing
plants
in the UK.
3.. When the reliability of spot tests, McDiarmid, has been confirmed
all personnel should be tested routinely when they visit these
and other
areas where DU has been fired.
4.. Biological testing should go alongside the urine analysis,
using the
tests outlined above 5.
5.. There should be autopsy and biopsy material obtained from
all GWVs
and any others contaminated with DU to establish the major sites
of its
distribution in the body and to obtain the necessary data to understand
the biokinetics of insoluble DU material.
f.. In vivo tests for DU should be contamination should be made
available as a matter of urgency.
7.. The ICRP models and calculation must be re-assessed in the
light of
the most recent information about low level radiation. Although
the
Working Group included a 100-fold increase in their calculated
risk
factors this does not even begin to match the huge differences
between
dose and dose-rates found in many studies- these range from several
hundred to several thousand fold. [In discussion it became clear
that
the WHO and the European parliament are now seeking an urgent
reconsideration of the ICRP models in the light of information
supplied
by the Low Level Radiation Campaign.]
8.. Firing tests under controlled conditions are unlikely to provide
significantly more useful information.
a.. The Big
Picture shows that activities of the whole of the nuclear
industry and its commercial, military and government extensions
are
unacceptable if the association of increased cancers is found
with low
levels of radiation arising from DU munitions and other sources-
fall
out, releases from nuclear processing plants and power stations.
It is
the end of the nuclear experiment. This unpalatable fact has not
been
considered in the Report. [In discussion it was stated that the
UK does
not sell DU munitions to any other country. This is difficult
to verify
but it is thought that up to 41 different countries now have DU
munitions and it is clear from copies of import licences that
weapons
manufactured at Springfields in the UK used DU imported from the
USA.
b.. BBC Scotland
carried out a brief study of the contamination of
people in three locations in the Balkans recently. Sample collection
and
analysis were carried out by respected and well-known scientists.
They
found every one they tested was excreting DU, some in very high
measure.
Indeed the camera man who accompanied the crew also tested positive
after just a five days in these countries. This is a remarkable
observation that demands an immediate and more extensive study.
It shows
that the movement of DU in the environment is unpredictable and
emphasises the need for direct measurements on these populations.
c.. Of value
in the Report
1.. The recognition that Gulf War Syndrome/Illness is multifactorial.
2.. The modelling of embedded shrapnel cannot be carried out using
existing models. Insoluble, immobilised DU ceramic particles may
fall in
this same category.
3.. Synergy of the radiological and toxicological actions of DU.
This
needs to be extended and include synergy between DU and the other
major
toxic exposures of the Gulf War-pyridostigmine bromide, vaccines,
pesticides, oil and smoke, and chemical war agents.
4.. The need for autopsy and in vivo measurements of DU.
In a letter to the Independent, 27 Mar 2001 I wrote "Unless
the Working
Group requires direct measurements to be made on GWVs it will
be just
another paper exercise, another alibi for not directly addressing
the
health of the GWVs- in short a cover up." Sadly this has
proved to be the
largely the case. The report in its present form is unacceptable.
a.. What Next?
1.. In the discussions it became clear that the Working Group
would only
revisit this report with great reluctance and felt that their
conclusions on the radiological hazards of DU were beyond any
serious
challenge. I could not disagree more.
2.. Part 2 of the Working Group's study will be concerned with
only the
chemical toxicity of DU. This will divert attention from the importance
of the radiological exposures and it seems will be the only
consideration in civilian exposures since these are not considered
in
Part 1 of the report. This is clearly a nonsense.
3.. Chemical exposures are not insignificant and possible synergy
between radiological and chemical toxicity needs exploring although
I am
not aware of any studies of this kind at present. It is experimental
data not modelling that is required to address this important
issue.
4.. Any consideration of chemical toxicity must start with a thorough
consideration of the many steps taken to deal with lead and other
toxic
metals in our environment. In th elight of current regulations
scattering DU over the country side and introducing it into the
food/water chains is not acceptable.
References
Alvarez R. Risks
to uranium process workers. BMJ eletters 29th Jan 2001
available at http://www.bmj.com/cgi/eletters/322/7279/123
Bertell R. Internal
Bone Seeking Radionuclides and Monocyte Counts.
International Perspectives in Public Health 1993, 9, 21-25.
Bertell R. in
Metal of Dishonor, International Action Center, 1999. ISBN:
0-9656916-0-8. This provides a useful summary with references
to the
manipulaton of cancers risks, the low dose-slow dose discovery
by Petkau
in 1972!, free radical events initiated by radiation in the destruction
of
cell membranes, and the work of Burlakova on the chernobyl catastrophe.
Busby C. Science
on Trial: On the Biological Effects and Health Risks
following Exposure to Aerosols produced by the use of Depleted
Uranium
Weapons. Submission to the Royal Society Working Group, 2000-
available at
www.llrc.org/
Busby C. Wings
of Death, Green Audit Books, Aberystwyth, 1995.
De Sutter E.
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Durakoviae A.
Medical effects of internal contamination with uranium.
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Durakoviae A.
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El-Bayoumi.
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DC
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useful for its references to Military studies which have not been
reported
in the published literature.
Gofman J. Radiation-induced
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Most Toxic War in Western Military History. Evidence
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Kadim MA, Macdonald
DA, Goodhead DT, Lorimore SA, Marsden SJ, Wright EG.
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Kohnlein W.
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Available at http://www.foe.arc.net.au/kohnlein/kohnpaper4.html
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to Hazell O'Leary, US Secretary Department of Energy,
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Little JB. Induction of sister chromatid exchanges by
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